All forms of electricity generation have some
impact on the environment. Renewable sources avoid the chemical
and physical affects of fossil and nuclear fuels, but have the
capacity to affect aspects of the natural heritage (Annex 1).
There is a risk that the development of renewables could obscure
the need for the fundamental changes which will be required in
the pattern of energy consumption, in order not only to meet the
Kyoto emission obligations but to attain the higher and more stringent
reduction targets which are likely to follow. Developing renewable
energy could be used as a means of soaking up new energy demand
without reducing existing fossil fuel consumption. Current DTI
projections of energy use are for continued growth of around 0.5
per cent per annum. The top priority in energy policy should therefore
be to encourage energy needs to be reduced, through efficiency
measures and better use of waste heat, to reverse this trend for
continued growth. We support the development of renewable energy
as an integral part of the Government's Climate Change Programme;
and support the Government's stated commitment to achieving the
majority of the emissions reductions through energy conservation/reductions
in demand.

SNH recognises the importance of addressing
the issues of climate change, and the contribution which renewable
energy can make towards that programme. Renewable energy development
can also contribute to wider sustainability objectives, including
rural employment. SNH therefore supports the development of renewable
energy sources as a replacement for energy produced from fossil
fuels. However, renewable energy developments have the capability
of causing significant adverse impacts on landscapes, habitats
and individual species. A priority for renewables policy should
be to foster kinds of energy technology, and approaches to their
adoption, which are most likely to be consistent with overall
natural heritage objectives. In supporting the development of
renewables, SNH recognises that some change to some of Scotland's
landscapes may be unavoidable.

We seek a strategic approach in which renewable
energy development is guided towards the locations and the technologies
most easily accommodated within Scotland's landscapes and habitats
without adverse impact, and which safeguard elements of the natural
heritage which are nationally and internationally important.

One important element of the approach we seek
should be that much less emphasis should be placed on securing
renewable energy at least cost. SNH considers that the principle
should be that greenhouse gas emissions need to be reduced without
diminishing the overall quality of life, and this should include
protecting the high quality of the Scottish environment. The price
of services to consumers should not be driven down if in so doing
environmental costs are incurred.

THE PLANNING
SYSTEMANDTHE DEVELOPMENTOF RENEWABLE
ENERGY

SNH sees it as the role of the planning framework
to provide a basis for ensuring that renewable energy is developed
with due attention to limiting potential impacts on the natural
heritage and safeguarding areas deemed worthy of special protection.
If these aims are to be compatible with Government's current targets
for renewable energy, strong planning guidance will be required.
We would like to stress that the role of the planning system becomes
even more critical with the move to the new basis for subsidising
renewables output.

A strategic approach should be adopted to ensure
that renewables development is guided towards those areas, technologies
and types of development which have the least adverse environmental
impact.

Long-term

In the longer term it is likely to become necessary
to increase the proportion of generation from renewable sources
above current targets, so as to continue to reduce emissions of
carbon dioxide. This will become even more necessary if Government
decides not to replace Scotland's nuclear capacity. Strategic
decisions about which should be the preferred renewable technologies
to meet future energy needs, and how to encourage these, should
take full account of their impacts upon the natural heritage.
The visual impact of large-scale renewable generation means that
future bulk electricity supply is likely to be served best by
encouraging at least a proportion of such generation to take place
offshore.

Short to medium-term

In the short-medium term, in view of the potential
for technologies which are currently close-to-market to have adverse
impacts on landscapes and habitats, SNH considers that meeting
energy needs requires a strong strategic planning framework to
ensure that development is well-structured, with technology types
and development proposals guided towards areas which are able
to accept them with least impact on natural heritage quality.
Current generation targets could be met through a great variety
of development options in terms of the size, number, and spatial
distribution of individual components. A strategic approach is
likely to require appropriate action at national level to direct
development towards locations where overall impacts are likely
to be least, and at local level to direct development towards
appropriate siting and design.

The following general principles inform SNH's
views on proposals for renewables development:

 to accommodate future renewable energy
generation on the scale required to help in addressing climate
change, some change to some of Scotland's landscapes is likely
to be unavoidable. Development of a scale (individually or cumulatively)
that changes landscape character is likely to be preferred where
the landscape is already developed or visually man-modified, and
relatively close to centres of population. Areas which are highly
valued for recreation and amenity should however be safeguarded;

 we should seek to safeguard the qualities
of areas where natural heritage value is associated with low evidence
of human intervention;

 over the remaining area of Scotland,
renewable energy developments should be accommodated (individually
or cumulatively) without significant adverse impact on the character
of the landscapes into which they are placed or the natural heritage
value for which these areas are appreciated;

 SNH has encouraged exploration of
one or more locations for very large windfarms, substantially
larger than developed to date, to help meet a significant proportion
of Government's renewable energy targets in Scotland. Such sites
should be within or relatively close to the Central Belt or major
populations centres;

 particuarly in more populated parts
of the country, there may be pressure to locate renewable developments
in areas which are out of sight. This could displace developments
towards areas where natural heritage values depend upon low human
impact. The need to minimise overall natural heritage impact may
lead to resisting such displacement where it is likely to lead
to natural heritage impacts being greater than otherwise necessary;

 the impacts from new renewables developments
derive not only from the generating technology, but also from
the track infrastructure required to service them. SNH has encouraged
exploration of opportunities to place new developments in areas
where a track infrastructure already exists, eg in forestry; and

 SNH encourages exploration of the
natural heritage impacts of offshore renewable development. Outwith
areas of high value for marine wildlife, SNH expects the overall
impacts on the natural heritage to be lower when renewables developments
are situated offshore. SNH supports strategic exploration for
appropriate locations and the promotion of appropriate technologies.